Bellavita Land Corp.
Certificate of Tax Exemption No. PSH-270-21 • Bureau of Internal Revenue (BIR) Issuances • Rulings (Numbered) • Jul 26, 2021
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July 26, 2021 CERTIFICATE OF TAX EXEMPTION NO. PSH-270-21 CERTIFICATE OF TAX EXEMPTION TO ALL WHOM IT MAY CONCERN : This certifies that BELLAVITA LAND CORP. 1 with Taxpayer Identification Number (TIN) 000-000-000-000, is exempt from income tax and creditable withholding tax (CWT) pursuant to Section 20 (d) (1) of Republic Act (RA) No. 7279, as amended by RA No. 10884 (Balanced Housing Development Program Amendments) dated July 17, 2016, on its income received directly in connection with its sale of socialized house and lot units for residential and dwelling purposes to qualified beneficiaries in Bellavita-General Trias, Cavite ,consisting of 307 2 house and lot units, located at Brgy. Tapia, General Trias, Cavite, a project duly registered with the Housing and Land Use Regulatory Board (HLURB) 3 under Certificate of Registration No. 25656 and Provisional License to Sell No. 248. Moreover, the sale by the Company of residential lot valued at P1,919,500.00 and below, or house and lot and other residential dwellings valued at P3,199,200.00 and below, is exempt from value-added tax (VAT) pursuant to Section 109 (1) (P) of the National Internal Revenue Code (Tax Code) of 1997, as amended. Provided, however, that beginning January 01, 2021, the exemption from VAT shall only apply to sale of house and lot and other residential dwellings 4 with selling price of not more than P2,000,000.00, as adjusted in 2011 using the 2016 Consumer Price Index values. 5 It is observed, however, that documentary stamp tax (DST) is not one of the taxes covered by the tax exemption clause in Section 20 of RA No. 7279. Thus, the documents conveying the properties shall be subject to DST imposed under Section 196 of the Tax Code of 1997, as amended, based on the consideration contracted to be paid for such realties or on their fair market value determined in accordance with Section 6 (E) of the same Code, whichever is higher. Likewise, lots/units classified as Economic Housing, not being covered by RA No. 7279, shall be subject to the payment of appropriate taxes. The grant of tax exemption herein is subject to the compliance with the provisions of applicable BIR rules and regulations and the Terms and Conditions stated hereof. The Company is liable, however, for other applicable taxes not discussed above. This Certificate of Tax Exemption is being issued on the basis of the facts and documents as represented and submitted. However, if upon investigation, the BIR ascertains that the facts are different, then this Certificate shall be considered null and void. Issued this 26th day of July, 2021. (SGD.) CAESAR R. DULAY Commissioner of Internal Revenue ATTACHMENT TERMS AND CONDITIONS OF THE CERTIFICATE OF TAX EXEMPTION 1. The exemption from income and creditable withholding taxes covers only income directly attributable to the revenues generated from the 307 socialized house and lot units in Bellavita-General Trias, Cavite ,located at Brgy. Tapia, General Trias, Cavite. 2. The developer shall submit the sworn statement of the buyer that he is eligible as a socialized housing beneficiary under Section 5 (A) of Revenue Regulations (RR) No. 11-97 to the Bureau of Internal Revenue (BIR) during the processing of the Certificate Authorizing Registration (CAR) for the transfer of the title of the socialized housing unit. 3. It is understood that the CAR shall only be issued after it is established upon proper verification by the Revenue District Officer (RDO) concerned that, considering the rules on valuation of real property, the actual selling price per sale transaction of the socialized house and lot packages in this case does not really exceed P450,000.00 on the 157 house and lot units and P400,000.00 on the 150 house and lot units. ANNEX A The following are to be sold as socialized house and lot units with maximum selling price of P450,000.00 per unit: 1. Per HLURB's letter dated May 23, 2019 granting the upgrading of selling price from P400,000.00 to P450,000.00: Block Lot 23 8 1 42 8 1 53 16 1 Total 3 2. Per HLURB's letter dated September 20, 2018 granting the upgrading of selling price from P400,000.00 to P450,000.00: Block Lot 49 7 1 50 5 1 52 17 1 Total 3 3. Per HLURB's letter dated January 05, 2017 granting the upgrading of selling price from P400,000.00 to P450,000.00: Block Lot 7 14 1 24 3 1 Total 2 4. Per HLURB's letter dated June 10, 2016 granting the upgrading of selling price from P400,000.00 to P450,000.00: Block Lot Block Lot 2 17 1 20 3, 6 2 5 14 1 24 2 1 7 11 1 46 6 1 12 7 1 47 10 1 14 15 1 49 15 1 15 5 to 6, 11 3 50 3 1 16 5 1 51 15 1 19 6 1 TOTAL 18 5. Per HLURB's letter dated June 10, 2015 granting the upgrading of selling price from P400,000.00 to P450,000.00: Block Lot Block Lot 2 12, 14, 16 3 31 3 1 3 5, 8 to 11, 15 to 20 11 32 8 to 9 2 5 7 to 8, 11 3 33 8 to 9 2 6 2 to 3 2 34 2 to 3, 7 to 8 4 7 10, 16, 24, 30 4 35 2, 3 2 8 2, 5, 11 3 36 3, 7 2 9 5 to 6 2 37 3 1 11 3, 5 to 9, 16 to 17 8 38 3, 7 2 12 2, 5 to 6 2 39 3, 5 to 6 3 14 5, 7, 10 to 11, 14 5 40 2 to 3, 9 to 11 5 15 2, 7 to 8 3 41 5, 8 2 16 2 to 3, 12, 14 4 42 3, 5, 9 3 17 5 1 43 3, 9 2 19 3, 5, 16 3 45 3 1 20 5, 11 2 46 5, 9 to 11 4 21 3, 5, 9 3 47 3, 6 to 7, 12 4 22 5 1 48 5, 7, 12 3 23 5 1 49 5 to 6 2 24 7 1 50 6, 11 2 25 3 1 51 5, 7 to 8, 16 to 18 6 28 7 to 10 4 52 5 to 7, 15, 18 5 29 3, 5 2 53 15 1 30 5, 8 2 Total 131 Footnotes 1. Formerly: South Maya Ventures Corporation. 2. Out of the 307 house and lot units, 157 house and lot units shall not be sold for more than 450,000.00 per unit as enumerated and identified in Annex "A" hereof, while the remaining 150 house and lot units shall not be sold for more than P400,000.00 per unit. 3. Now: Department of Human Settlements and Urban Development (DHSUD). 4. Sale of lot only, regardless of the price, shall be subject to VAT starting January 01, 2021 pursuant to RA No. 10963. 5. Per Revenue Regulations No. 4-2021 dated April 8, 2021.
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